Representative Legal Matters
Altera Corp. & Subsidiaries v. Commissioner, 145 T.C. No. 3 (2015), rev’d, 926 F.3d 1061 (9th Cir. 2019) (challenge to the validity of transfer pricing regulations).
FedEx Corp. & Subsidiaries v. United States, U.S. District Court for the Western District of Tennessee, No. 2:20-cv-02794 (challenge to the validity of regulations under section 965)
Guardian Industries Corp. v. United States, US District Court for the District of Michigan, No. 4:16-cv-1911 (suit for refund of penalties for failure to file information returns of foreign corporations).
Gubser v. Internal Revenue Service, US District Court for the Southern District of Texas, No. 5:15-cv-00298, US Court of Appeals for Fifth Circuit, No. 16-40948 (declaratory judgment suit regarding the standard for proving a willful FBAR penalty).
Maze v. Internal Revenue Service, US District Court for the District of Columbia, No. 1:15-cv-01806, US Court of Appeals for the D.C. Circuit, No. 16-70496 (suit challenging the validity of rules under the Offshore Voluntary Disclosure Program).
Whirlpool Financial Corp. v. Commissioner, U.S. Court of Appeals for the Sixth Circuit, Nos. 20-1899, 20-1900 (application of Subpart F Manufacturing Branch Rules to Mexican manufacturing company)
- U.S. Court of Appeals, Sixth Circuit~United States (2020)
- U.S. District Court, Western District of Tennessee~United States (2020)
- U.S. Supreme Court~United States (2016)
- U.S. Court of Appeals, Ninth Circuit~United States (2016)
- U.S. Court of Appeals, Fifth Circuit~United States (2016)
- U.S. District Court, Eastern District of Michigan~United States (2016)
- U.S. Court of Appeals, D.C. Circuit~United States (2016)
- U.S. District Court, District of Columbia~United States (2015)
- Tennessee~United States (2014)
- U.S. Tax Court~United States (2009)
- District of Columbia~United States (2006)
- North Carolina~United States (1999)
- Georgetown University (LL.M. Taxation Distinction) (2008)
- Wake Forest University (J.D. cum laude) (1999)
- University of Tennessee (B.A. summa cum laude) (1996)
- Author, “The Rise of Footnote 9 (And Why Some TCJA Regulations Fail Chevron Step One),” TAXES the Tax Magazine, March 2020
- Co-author, "Chamber of Commerce Shows the Vulnerability of In Terrorem IRS Notices," TAXES the Tax Magazine, March 2018
- Author, “The Upsides and Downsides of Ending Chevron Deference,” Tax Notes, The Star Forum, March 2017
- Co-author, "Treasury Issues Temporary and Final Code Section 385 Regulations," Baker & McKenzie, Tax News and Developments Client Alert, November 2016